Legal, Privacy and Whistleblowing

by

1. TERMS OF USE

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING OUR WEBSITE.

  1. By using our website you accept these terms

1.1 By browsing on CCL Impex Pte. Ltd.’s website (the Website), you confirm that you accept these terms and conditions of use and that you agree to comply with them.

1.2 If you do not agree to these terms, you must not use our Website.

1.3 We recommend that you print a copy of these terms of service for future reference.

  1. There are other terms that may apply to you

These terms of service refer to our Privacy Policy, which apply to your use of our Website.

  1. We may make changes to these terms

We may amend these terms from time to time. Every time you wish to use our Website, please check these terms to ensure you understand the terms that apply at that time.

  1. We may modify, suspend or withdraw our site

4.1 We reserve the right to update or modify our Website from time to time. We do not guarantee that our Website, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our Website at any time without ascribing any reasons.

4.2 You are also responsible for ensuring that all persons who access our Website through your internet connection are aware of these terms of service and other applicable terms and conditions, and that they comply with them.

  1. Proprietary rights

5.1 This Website is owned and operated by CCL Impex Pte. Ltd. (we, our, us, CCL).

5.2 The materials located on the Website, including the information as well as any software programmes made available on or through this Website (the Contents), are protected by copyright, trademark and other forms of proprietary rights. All rights, title and interest in the Contents are owned by, licensed to or controlled by CCL.

  1. Restrictions on use of materials

6.1 Except as otherwise provided, the Contents of this Website shall not be produced, republished, uploaded, posted, transmitted or otherwise distributed in any way, without the prior written permission of CCL.

6.2 You must not use any part of the Contents of this Website for commercial purposes without obtaining a license to do so from us or our licensors.

6.3 Modification of any of the Contents or use of the Contents for any other purpose will be a violation of CCL’s copyright and other intellectual property rights. Graphics and images on this Website are protected by copyright and may not be reproduced or appropriated in any manner without the written permission of their respective copyright owners.

6.4 If you print off, copy or download any part of this Website in breach of these terms of service, your right to use this Website will cease immediately and you must, at our option, return or destroy any copies of the material you have made.

  1. Disclaimer of liability

7.1 The Contents of this Website are provided on an “as is” basis without warranties of any kind. To the fullest extent permitted by law, CCL does not warrant and hereby disclaim any warranty:

  • (a) as to the accuracy, correctness, reliability, timeliness, non-infringement, title, merchantability or fitness for any particular purpose of the Contents of this Website; and
  • (b) that the Contents available through this Website or any functions associated therewith will be uninterrupted or error-free, or that defects will be corrected or that this Website and the server will be free of all bugs, viruses, and/or other harmful elements.

7.2 We shall not be liable for any damage or loss of any kind, however caused as a result (indirect or direct) of the use of this Website, including but not limited to any damage or loss suffered as a result of reliance on the Contents contained or available from this Website.

7.3 The Contents of this Website do not constitute financial, legal or other professional advice. If financial, legal or other professional advice is required, services of a competent professional should be sought.

7.4 You are responsible for configuring your information technology, computer programs and platform to access our Website. You should use your virus protection software.

  1. We are not responsible for websites we link to

Where our Website contains links to other websites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them. We have no control over the contents of those websites or resources.

  1. Uploading information to our site

11.1 Whenever you make use of a feature that allows you to upload information, text, graphics, photographs or other materials (Information) to this Website, or to make contact with other users of this Website, you must comply with the content standards set out in Clause 11.2.

11.2 The Information uploaded to this Website must not:

  • (a) be in breach of any law or regulation, or any guidelines or other instrument issued by any government or regulatory authority, including but not limited to the Internet Code of Practice at https://www.imda.gov.sg/-/media/Imda/Files/Regulations-and-Licensing/Regulations/Codes-of-Practice/Codes-of-Practice-Media/PoliciesandContentGuidelinesInternetInterneCodeOfPractice.pdf;
  • (b) contain the following:
    • (i) offensive content, such as defamatory content, content involving violence, cruelty, nudity, sex, sexual deviancy, pornography, sexual degradation, solicitation of prostitution, offensive language, crude references or hate speech; or content which is indecent, obscene, false or offensive in character, regardless of whether there is malice or intention to annoy, abuse, threaten or harass any person;
    • (ii) content which is unsuitable for users aged 18 and below;
    • (iii) content promoting terrorism or terror-related activities;
    • (iv) content involving references to physical, mental or sensory disability;
    • (v) content which encourages the public to engage in or promote unlawful acts, violence, selling or consuming narcotics, psychotropics or other addictive substances;
    • (vi) inflammatory, subversive or seditious content, such as content which incites or promotes conflict against the country or any state, its constitution, government or laws; or incites or promotes conflict between groups, ethnicities, races, religions or genders, or degrade religious or cultural beliefs;
    • (vii) content involving gambling, such as games, lotteries, horse-racing, sports betting, astrology, geomancy, palm reading or any other type of fortune-telling device;
    • (viii) content involving minors without the written consent of such minor’s parent or legal guardian;
    • (ix) content relating to or promoting content prohibited or banned under any law;
    • (x) content which infringes intellectual property rights or causes confusion on the relationship with other organisations or individuals;
    • (xi) content involving the impersonation of organisations or individuals without such organisations’ or individuals’ written consent; and
    • (xii) content violating data protection laws and intellectual property laws.

11.3 You warrant that any such contribution does not contain the prohibited content in Clause 11.2, and you will be liable to us and indemnity us for any breach of that warranty. This means you will be responsible for any loss or damage we suffer as a result of your breach of warranty.

11.4 Any Information you upload to this Website will be considered non-confidential and non-proprietary. You retain all of your ownership rights in your Information, but you are required to grant us and other users of this Website a limited licence to use, store and copy that Information and to distribute and make it available to third parties.

11.5 We also have the right to disclose your identity to any third party who is claiming any Information you posted or uploaded to this Website constitutes a violation of their intellectual property rights or of their right to privacy, in accordance with our Privacy Policy.

11.6 We have the right and absolute discretion to remove any posting you make on this Website without any prior notice or providing any reason for such removal.

  1. Governing law

12.1 These terms of service shall be governed and construed in accordance with the laws of Singapore.

12.2 Any dispute arising out of or in connection with this policy, including any question regarding its existence, validity or termination will be submitted to the jurisdiction of the Singapore courts.

 

 

 

 



2. PRIVACY POLICY

 

1. Does this Privacy Notice apply to you?

This Privacy Notice applies to you if you are a customer of CCL, a recipient of an order package delivered by CCL, a supplier of CCL, or if you contact CCL, for instance, by visiting www.cclimpex.com.sg, using social media or if you receive emails from CCL.

2. What information does CCL collect?

In the course of its business activities and providing the services, CCL will need to process personal data. “Personal Data” is any information that can directly or indirectly be used to identify a natural person. You provide most of your Personal Data directly to CCL, for instance:

  • Contact information. Such as your name, address, e-mail address and phone number;
  • Financial information. Such as your bank account number, payment status, invoices;
  • Identification information. Such as your driver’s license number;
  • Account information. Log-in details, including your email address and password, and other information provided in your account;
  • Information related to shipment and services. Such as shipment tracking number, shipment routing information, location data, status of a shipment, delivery location, packaging type, number of pieces, weight, picture of the parcel, custom’s information;
  • User and preference information. Such as shipping amounts, complaints, history of purchases and related commercial activities, communication, survey information, shipping preferences.

3. Purposes for collection, use and processing of Personal Data by CCL

Personal Data shall be collected, used, stored or otherwise processed if necessary within the framework of responsible, efficient and effective business management of CCL. We process Personal Data because it is necessary to perform our obligations with you, or it is necessary for us to comply with our legal obligations, or for other legitimate business interests of CCL to provide quality and secure order processing and shipping Services.

More specifically, CCL uses Personal Data for the following activities:

  • Product development, research and improvement of CCL products and/or services. CCL processes Personal Data as necessary for the development and improvement of CCL products and/or services, research and development.
  • Performing agreements. This includes CCL’s services, communication with you and other parties regarding services, responding to requests for (further) information, dispute resolution and preparing agreements.
  • Relationship management and marketing for commercial activities. CCL may process Personal Data as necessary for the development and improvement of CCL products and/or services, account management, client service and the performance of (targeted) marketing activities in order to establish a relationship with a client and/or maintaining as well as extending a relationship with a client, business partner or supplier and for performing analyses with respect to Personal Data for statistical and scientific purposes.
  • Business process execution, internal management and management reporting. This includes addressing activities such as managing company assets, conducting internal audits and investigations, finance and accounting, implementing business controls, provision of central processing facilities for efficiency purposes, managing mergers, acquisitions and divestitures and Processing Personal Data for management reporting and analysis.
  • Safety and security. Personal Data may be included in the processing for activities such as those involving safety and health, the protection of CCL and customer, supplier or business partner assets and the authentication of customer, supplier or business partner status and access rights.
  • Protecting the vital interests of individuals. This includes processing data when necessary to protect the vital interests of an individual (e.g. for urgent medical reasons).
  • Compliance with legal obligations. This addresses the processing of Personal Data as necessary for compliance with laws, regulations and sector specific guidelines to which CCL is subject (e.g. matching names of clients, suppliers and business partners against denied lists).

The following paragraph describes our commitment to the protection of Personal Data as it applies to the CCL website (www.cclimpex.com.sg) or any of its subpages through which CCL may obtain Personal Data automatically.

This Personal Data is obtained through the use of cookies or similar technologies.

Some of the examples (non-exhaustive) where we may collect personal data of a user are:

  1. When a user signs up for alerts or newsletters;
  2. When a user visits CCL’s websites;
  3. When a user (or someone on his/her behalf) contacts CCL for queries, requests or feedback;
  4. When a user participates in CCL’s marketing or promotional events; or

CCL uses this Personal Data for the following purposes:

  • help us and third parties obtain information about your visits to the sites
  • process your orders and shipments
  • analyse your visiting patterns to improve our sites
  • deliver advertising, communications and content from us and third parties, on our sites and those of third parties, specific to your interests
  • remember your language and other preferences
  • help you obtain information you are looking for
  • provide a safe and secure service for online transactions
  • measure how many people use our sites, and how they use them, to keep our sites running efficiently and to better understand our audiences
  • system administration and troubleshooting

4. Who has access to your Personal Data?

CCL may share your Personal Data with third parties in the following circumstances:

  • CCL may share your Personal Data with its affiliates, operating groups, subsidiaries and divisions, or with third parties if such is necessary for the purposes as listed above. If appropriate, CCL will require third parties to conduct activities in a manner consistent with CCL policies and guidelines in relation to data protection.
  • CCL may share your Personal Data with data processors, i.e. parties processing Personal Data on our behalf. In such cases, these third parties may only use your Personal Data for the purposes described above and only in accordance with our instructions. CCL will only use processors which provide sufficient guarantees to implement appropriate technical and organizational measures and ensure the protection of the rights of data subjects.
  • CCL employees may have access to your Personal Data if necessary for the performance of their tasks. In such a case, access will be granted only if necessary for the purposes described above and only if the employee is bound by confidentiality.
  • CCL may share your Personal Data if required to do so by law, court order, or other legal process, for example, with law enforcement agencies or other governmental agencies, to establish or exercise our legal rights or in connection with a corporate transaction, such as a divesture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
  • Besides the mentioned purposes, CCL will not sell, rent or give away Personal Data to third parties for commercial purposes without the Customers/vendors/suppliers’ consent

5. How long will CCL process your Personal Data?

CCL retains your Personal Data for a limited amount of time and will delete your Personal Data as soon as it is reasonable to assume that:

(a) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and

(b) retention is no longer necessary for any other legal or business purposes.

The exact period of time is based on the type of the Personal Data and the legal obligations or business purposes for retaining it.

 

6. What measures does CCL take to protect your Personal Data?

CCL has taken appropriate technical and organizational measures to protect your Personal Data against accidental or unlawful processing, including by ensuring that:

  • your Personal Data is protected against unauthorized access;
  • the confidentiality of your Personal Data is assured;
  • the integrity and availability of your Personal Data will be maintained;
  • personnel is trained in information security requirements; and
  • actual or suspected data breaches are reported in accordance with applicable law.

7. Transfer of data to other countries.

Due to the nature of our business and the services we provide to our clients, CCL may need to transfer your Personal Data to locations outside the country where you reside. In any case where we transfer Personal Data, CCL shall ensure that such a transfer is subject to appropriate safeguards.
For more detailed information about these safeguards, please contact CCL, at [email protected].

8. What if I have other questions or feedback?

Questions or feedback can be directed at [email protected].



4. LIMITATION OF LIABILITY

4.1 TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE SERVICES PROVIDED BY CCL ON OR THROUGH THE SITES ARE PROVIDED “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS”, AND CCL HEREBY EXPRESSLY DISCLAIMS ANY AND ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO, ANY WARRANTIES OF CONDITION, QUALITY, DURABILITY, PERFORMANCE, ACCURACY, RELIABILITY, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. ALL SUCH WARRANTIES, REPRESENTATIONS, CONDITIONS, AND UNDERTAKINGS ARE HEREBY EXCLUDED.

4.2 TO THE MAXIMUM EXTENT PERMITTED BY LAW, CCL MAKES NO REPRESENTATIONS OR WARRANTIES ABOUT THE VALIDITY, ACCURACY, CORRECTNESS, RELIABILITY, QUALITY, STABILITY, COMPLETENESS OR CURRENTNESS OF ANY INFORMATION PROVIDED ON OR THROUGH THE SITES; CCL DOES NOT REPRESENT OR WARRANT THAT THE MANUFACTURE, IMPORTATION, EXPORT, DISTRIBUTION, OFFER, DISPLAY, PURCHASE, SALE AND/OR USE OF PRODUCTS OR SERVICES OFFERED OR DISPLAYED ON THE SITES DOES NOT VIOLATE ANY THIRD PARTY RIGHTS; AND CCL MAKES NO REPRESENTATIONS OR WARRANTIES OF ANY KIND CONCERNING ANY PRODUCT OR SERVICE OFFERED OR DISPLAYED ON THE SITES.

4.3 Any material downloaded or otherwise obtained through the Sites is done at each User’s sole discretion and risk and each User is solely responsible for any damage to CCL’s computer system or loss of data that may result from the download of any such material. No advice or information, whether oral or written, obtained by any User from CCL or through or from the Sites shall create any warranty not expressly stated herein.

4.4 The Sites may make available to User services or products provided by independent third parties. No warranty or representation is made with regard to such services or products. In no event shall CCL and our affiliates be held liable for any such services or products.

4.5 Each User hereby further agrees to indemnify and save CCL, our affiliates, directors, officers and employees harmless, from any and all losses, damages, claims, liabilities (including legal costs on a full indemnity basis) which may arise, directly or indirectly, as a result of any claims asserted by Third Party Rights claimants or other third parties relating to products offered or displayed on the Sites. Each User hereby further agrees that CCL is not responsible and shall have no liability to you, for any material posted by others, including defamatory, offensive or illicit material and that the risk of damages from such material rests entirely with each User. CCL reserves the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you shall cooperate with CCL in asserting any available defenses.

4.6 CCL shall not be liable for any special, direct, indirect, punitive, incidental or consequential damages or any damages whatsoever (including but not limited to damages for loss of profits or savings, business interruption, loss of information), whether in contract, negligence, tort, equity or otherwise or any other damages resulting from any of the following:

  1. a) the use or the inability to use the Sites or Services;
  2. b) any defect in goods, samples, data, information or services purchased or obtained from a User or any other third party through the Sites;
  3. c) violation of Third Party Rights or claims or demands that User’s manufacture, importation, export, distribution, offer, display, purchase, sale and/or use of products or services offered or displayed on the Sites may violate or may be asserted to violate Third Party Rights; or claims by any party that they are entitled to defense or indemnification in relation to assertions of rights, demands or claims by Third Party Rights claimants;
  4. d) unauthorized access by third parties to data or private information of any User;
  5. e) statements or conduct of any User of the Sites; or;
  6. f) any matters relating to Services however arising, including negligence.

 

4..7 The limitations and exclusions of liability to you under the Terms shall apply to the maximum extent permitted by law and shall apply whether or not CCL has been advised of or should have been aware of the possibility of any such losses arising.





5. APPLICABLE LAWS

This Agreement shall be governed by the laws of Singapore without regard to its conflict of laws rules. You expressly agree that exclusive jurisdiction for any claim or dispute with CCL or relating in any way to your use of the CCL Service or the CCL Platform resides in the federal and state courts of Singapore and you further expressly consent and agree to personal jurisdiction by the state and federal courts sitting in Singapore in connection with any such dispute, including any claim involving CCL Parties. Any cause of action by you must be instituted within one year after the claim or cause of action has arisen, or it shall be barred. If any provision of these Terms of Use is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms of Use, which shall remain in full force and effect. No waiver of any of these Terms of Use shall be deemed a further or continuing waiver of such term or condition or any other term or condition.



6. NOTICE AND TAKE DOWN PROCEDURES

If you believe any Submission accessible on or from the Platform infringes your copyright, you may request removal of those materials (or access thereto) from this Platform by contacting CCL(email address identified below) and providing the following information:

  1. Identification of the copyrighted work that you believe to be infringed. Please describe the work, and where possible include a copy or the location (e.g., URL) of an authorized version of the work.
  2. Identification of the Submission that you believe to be infringing and its location. Please describe the Submission, and provide us with its URL or any other pertinent information that will allow us to locate the Submission.
  3. Your name, address, telephone number, and (if available) email address.
  4. A statement that you have a good faith belief that the complained of use of the work is not authorized by the copyright owner, its agent, or the law.
  5. A statement that the information you have supplied is accurate, and indicating that “under penalty of perjury,” you are the copyright owner or authorized representative.
  6. A signature or the electronic equivalent from the copyright holder or authorized representative.
  7. Our email address for copyright issues relating to this Platform is as follows:

Attn: [email protected]

Subject Title: Take Down copyrighted work

  1. In an effort to protect the rights of copyright owners, CCL maintains a policy for the termination, in appropriate circumstances, of users of this Platform who are repeat infringers.